Institute for Policy Integrity

Twitter @policyintegrity

What We Do

Project Updates

  • Public Comments

    Comments on Proposed Offshore Leasing Program for 2017-2022

    June 16, 2016

    We recently submitted comments to BOEM in response to its proposed five-year offshore leasing program for 2017-2022. In its proposed program, BOEM qualitatively considers the option value, or informational value of delaying leasing until more information is available on relevant environmental, social, and technological uncertainties. In addition, BOEM will now consider environmental and social costs in its “hurdle price” analysis that helps determine whether and when to offer areas for lease. Building on this progress, we recommend that BOEM take additional steps to strengthen its analysis in line with best practices and OCSLA’s mandate to balance economic, social, and environmental values.

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  • News

    Revesz Testifies at Senate Hearing on Clean Power Plan

    June 9, 2016

    On June 9, Richard Revesz testified at a Senate Environment and Public Works Committee hearing focused on the Supreme Court’s stay of the Clean Power Plan.

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  • Public Comments

    National Academy of Sciences Reviews Social Cost of Carbon

    April 29, 2016

    The National Academy of Sciences (NAS) is currently conducting a review of the methodologies used to calculate the Social Cost of Carbon (SCC). We submitted comments to NAS to help inform this process.

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  • Public Comments

    Distributed Energy Compensation Comments for NARUC

    April 29, 2016

    As distributed energy resources (“DER”) are becoming increasingly common, the debate on how customers with such systems should be compensated is intensifying in many states. The National Association of Regulatory Utility Commissioners (NARUC) is creating a Distributed Energy Resources Compensation Manual to assist states with these policy decisions. We recently submitted comments to NARUC’s Staff Subcommittee on Rate Design regarding the most economically desirable approach to use for DER compensation.

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  • Public Comments

    New York Clean Energy Standard - White Paper Comments

    April 22, 2016

    The 2015 New York State Energy Plan set one of the most ambitious clean energy targets in the nation: 50 percent of all electricity used in the state should be generated by renewable energy sources. The Department of Public Service Staff recently released a White Paper on the Clean Energy Standard, with recommendations on how to achieve this ambitious goal. We submitted comments to the New York State Public Service Commission, outlining some additional steps that can help ensure that the Clean Energy Standard is not excessively costly, and is effective in achieving all of its policy goals.

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  • Public Comments

    Comments on BLM Rule to Control Fugitive Methane Emissions

    April 22, 2016

    We recently submitted two sets of public comments to the Bureau of Land Management (BLM) regarding a proposed rule to reduce waste of natural gas from venting, flaring, and leaks during oil and gas production on federal and Indian lands. BLM has proposed making natural gas lost through these processes subject to royalty payments.

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  • Public Comments

    Comments on Net Metering and Distributed Energy Valuation in New York

    April 18, 2016

    We recently submitted comments to the New York Public Service Commission on how the Commission should develop an interim successor to its net metering policy, and how distributed energy resources should be valued in the future. We filed the comments jointly with the Environmental Defense Fund. To begin to move the retail electricity markets toward efficient and accurate recognition of the value of distributed energy resources, we suggest that the Commission should enhance its existing net energy metering policy to align compensation with the system benefits provided by distributed energy resources; establish a fully unbundled retail price structure; and specifically account for the environmental benefits of distributed energy resources in future pricing structures.

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  • Public Comments

    Comments on FDA Proposal to Restrict Artificial Tanning

    April 4, 2016

    We recently submitted comments in response to the Food and Drug Administration’s (FDA) proposed rule to restrict the use of sunlamps used for artificial tanning. We concluded that although the proposed rule takes a significant step in reducing the risks of artificial tanning, the FDA should strengthen the justification for this proposed rule.

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  • Court Filings

    Brief for Clean Power Plan Litigation

    April 1, 2016

    We recently submitted an amicus brief in the litigation over the EPA’s Clean Power Plan, which regulates carbon dioxide emissions from the power sector. A group of coal companies and states is asking the U.S. Court of Appeals for the D.C. Circuit to strike down the rule, arguing that it represents an unprecedented expansion of the EPA’s regulatory authority. Our brief shows that, in fact, there are regulatory precedents for every aspect of the rule that petitioners claim is unprecedented. Our analysis of past EPA regulations and court rulings reveals that the Clean Power Plan is consistent with decades of Clean Air Act practice under administrations of both parties.

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  • Jayni Hein Addresses IEL’s Annual Oil and Gas Conference

    February 19, 2016

    On February 19th, our Policy Director, Jayni Hein, presented at the Institute for Energy Law’s Annual Oil and Gas Law Conference in Houston. Speaking on a panel titled “How Revenues Should be Collected for the Use of Federal Lands for Energy Development.”

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